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    <section>
        <h1>PRIVACY POLICY</h1>
    </section>
    <section id="section-01">
        <h3>Information We Collect From You</h3>
        <p>
            We value your trust in providing us your personal information. TOPCOSMOS TECHNOLOGY LIMITED UNIT A17, 29/F,
            LEGEND TOWER, NO.7 SHING YIP STREET, KWUN TONG, KOWLOON, HONG KONG (“
            <b>BitTopup</b>
            ”) does not share, disclose or sell any personally-identifiable information (such as your name, address,
            telephone number or email address) collected online on bittopup’s sites with other unaffiliated companies or
            organizations for non-bittopup marketing purposes. Because this information is a critical part of our
            business, it would be treated like our other assets in the context of a merger, sale or other corporate
            reorganization or legal proceeding.
        </p>
        <p>
            By using our Services (as defined in our Terms of Use), you acknowledge and agree that you accept the
            practices, requirements, and/or policies as set out below, and you hereby consent to us collecting, using,
            disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING
            OF YOUR PERSONAL DATA, YOU MAY NOT BE ABLE TO USE OUR SERVICES NOR HAVE FULL ACCESS TO OUR PLATFORM (as
            defined in our Terms of Use).
        </p>
    </section>
    <section id="section-02">
        <h3>Why We Collect Data From You</h3>
        <p>bittopup collects data from you for the following purposes:</p>
        <ol>
            <li>
                where it is necessary for the performance of our agreement with you to provide and deliver associated
                content and Services;
            </li>
            <li>where it is necessary for compliance with legal obligations that we may be subjected to; and/or</li>
            <li>where you have given consent to the same.</li>
        </ol>
    </section>
    <section id="section-03">
        <h3>We Are Responsible For Children’s Privacy</h3>
        <p>
            Protecting the privacy of young children is especially important. bittopup also does not market to, or
            knowingly collect personal information from, children under age of 13 on any sites of the company. If we
            become aware that we have collected personal information from a child under age 13 without verification of
            parental consent, we take steps to remove that information. In the event that personal data of a child under
            age 13 in your care is disclosed to bittopup, you hereby consent to the processing of the child’s personal
            data and accept and agree to be bound by this Policy on behalf of such child.
        </p>
    </section>
    <section id="section-04">
        <h3>When Can We Collect Your Personal Information?</h3>
        <p>We may collect personal information directly from you when you:</p>
        <ol>
            <li>register and/or use our Services or Platform;</li>
            <li>link your social media or other external accounts to register an account with us;</li>
            <li>
                communicate with us (including but not limited to attending to you through our online customer service
                chats, letters, fax, calls (which may be recorded), face-to-face meetings, social media platforms,
                emails
                etc.);
            </li>
            <li>
                register or subscribe for a specific Product and/or Service or our publications (for example,
                newsletters);
            </li>
            <li>participate in any of our surveys;</li>
            <li>
                enter into or participate in any competitions, contests or loyalty programs run/organized by bittopup;
            </li>
            <li>
                register interest and/or request for information of (through our online portals or other available
                channels)
                or subscribe to our Products and/or Services;
            </li>
            <li>respond to any marketing materials we send out;</li>
            <li>visit or browse our websites;</li>
            <li>lodge a complaint with us;</li>
            <li>provide feedback to us in any way; and/or</li>
            <li>submit your personal data to us for any reason.</li>
        </ol>
        <p>
            Other than personal information obtained from you directly (as detailed above), we may also obtain your
            personal information from third parties we deal with or are connected with you (credit reference agencies or
            financial institutions), and from such other sources where you have given your consent for the disclosure of
            information relating to you, and/or where otherwise lawfully permitted.
        </p>
    </section>
    <section id="section-05">
        <h3>How Can We Collect Your Personal Information?</h3>
        <p>
            bittopup collects information online by asking you for it, for example, when you order a service, apply for
            a
            job, or respond to a survey, offer or other promotion. A customer’s name, address (postal and email) and
            telephone number are the most important pieces of information, but we might request other information, based
            on, for example, the service(s) being ordered or promoted.
        </p>
        <p>
            <b>Cookies:</b>
            bittopup may also use “cookies” and similar technology to obtain information about your visits to our sites
            or
            your responses to email from us – both individually and in aggregated data that does not identify you. These
            reporting tools tell us the parts of our web sites or e-mails in which you showed an interest or took some
            action, and help us improve the quality and usefulness of our sites.
        </p>
        <p>
            <b>Content:</b>
            You also provide us information in content you post to the website. Your content (such as reviews, photos
            and
            videos) and metadata about your content will be viewed by other users. bittopup can, but has no obligation,
            to
            monitor your content you post on the website. We can remove any information you post for any reason or no
            reason.
        </p>
        <p>
            <b>Payment Method:</b>
            You will also be asked to submit Personal Information depending on the payment method you choose when
            accessing, purchasing or subscribing to one of our products or services. For example, if you choose to pay
            for
            a product/service by credit card, you will be required to provide us the name of your credit card issuer,
            credit card number, billing address, CVV number, and expiration date.
        </p>
        <p>
            <b>Log Files:</b>
            When you use the website, our servers automatically record certain information sent by your web browser.
            These
            server logs may include information such as your web request, Internet Protocol (“IP”) address, browser
            type,
            referring / exit pages and URLs, number of clicks and how you interact with links on the website, domain
            names, landing pages, pages viewed, mobile carrier, and other such information.
        </p>
        <p>
            <b>Geo-Location Information:</b>
            When you use the website by or through a mobile device, we may access, collect, monitor and/or remotely
            store
            “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information
            regarding the location of your mobile device.
        </p>
        <p>
            <b>Device:</b>
            When you use bittopup.com, we may collect information about your devices such has device type, device
            hardware
            information, operating system type and version, device time and timezone, and other information necessary.
        </p>
        <p>
            <b>Third Party Tools:</b>
            bittopup uses third party analytics tools, to help understand use of the website. Many of these tools
            collect
            the information sent by your browser as part of a web page request, including cookies and your IP address.
            These analytics tools also receive this information and their use of it is governed by their privacy policy.
        </p>
        <p>
            <b>Other Data You Unequivocally Submit:</b>
            When you post, comment or follow any of our content and services, or send messages through our built-in
            online
            chat system, or provide us information in respect of any request or support required from us or for the
            purchase of our products and services, or participate in our competitions, contests, and tournaments, we may
            collect such information from you.
        </p>
    </section>
    <section id="section-06">
        <h3>What Personal Data Will We Collect?</h3>
        <p><b>Personal Information You Disclose to Us</b></p>
        <p>
            The personal information that we collect depends on the context of your interactions with us and the
            Services,
            the choices you make, and the products and features you use. The personal information we collect may include
            the following:
        </p>
        <ol>
            <li>name</li>
            <li>email address</li>
            <li>telephone number</li>
            <li>date of birth</li>
            <li>mailing and/or billing address</li>
            <li>username</li>
            <li>password</li>
            <li>contact preferences</li>
            <li>debit/credit card numbers</li>
            <li>
                financial information (eg: last four digits of your debit or credit card number, billing history,
                billing
                address, card type, issuing bank, expiration date, card origin by country)
            </li>
            <li>online survey records and details</li>
            <li>interests in our marketing campaigns and products</li>
            <li>cookie preferences</li>
        </ol>
        <p>
            <b>Sensitive Information.</b>
            When necessary, with your consent or as otherwise permitted by applicable law, we process the following
            categories of sensitive information: - financial data
        </p>
        <p>
            <b>Payment Data.</b>
            We may collect data necessary to process your payment if you make purchases, such as your payment instrument
            number, and the security code associated with your payment instrument. All payment data is stored by the
            respective payment channel partners. You may find our list of payment channel partners here:
            <a href="https://bittopup.com">bittopup.com</a>
        </p>
        <p>
            <b>Social Media Login Data.</b>
            We may provide you with the option to register with us using your existing social media account details,
            like
            your Facebook, Twitter, or other social media account. If you choose to register in this way, we will
            receive
            certain profile information about you from your social media provider. The profile information we receive
            may
            vary depending on the social media provider concerned, but will often include your name, email address,
            friends list, and profile picture, as well as other information you choose to make public on such a social
            media platform.
        </p>
    </section>
    <section id="section-07">
        <h3>How Can We Use Your Information</h3>
        <p>
            bittopup uses the personally-identifiable information collected online principally to provide you with the
            following service(s):
        </p>
        <ol>
            <li>processing orders and/or transactions you have made</li>
            <li>
                manage and administer your use of our Services including but not limited to remembering your preferences
            </li>
            <li>for identification, verification, due diligence or known your customer purposes</li>
            <li>
                deal with or facilitate customer service, carry out your instructions, deal with or respond to enquiries
                made by you or on your behalf
            </li>
            <li>
                contact you via voice call, text message, email and/or post or otherwise for the purpose of managing
                your
                relationship with us or your use of our Services. This includes allowing us to let you know about other
                offerings which may be of interest to you. Postal and e-mail address information, for example, enables
                communication about services offered and ordered, as well as the proper provisioning and billing of
                those
                services.
            </li>
            <li>
                conduct research, analysis and development activities (including but not limited to data analytics,
                surveys,
                products and service development and/or profiling) to analyze how you use our Services, to recommend
                products and/or services relevant to your interest, to improve our Services and/or to enhance your
                customer
                experience
            </li>
            <li>
                respond to legal processes or to comply with or as required by any applicable laws, governmental or
                regulatory requirements of any relevant jurisdiction, or where we have good faith to believe that such
                disclosure is necessary under any applicable law. This includes but not limited to in response to
                subpoenas
                and other legal demands, and where we believe that disclosing this information is necessary to identify,
                contact or bring legal action against individuals who may be endangering public safety or interfering
                with
                bittopup services, or with our customers’ or others’ use of them.
            </li>
            <li>
                deal with and/or facilitate asset sale transaction or potential asset sale transaction, where such
                transaction involves bittopup as a participant or involves a related company or affiliate of bittopup as
                a
                participant, and there may be other third party organizations who are participants to such transaction.
                An
                ‘asset sale transaction’ refers to the purchase, sale, lease, merger, amalgamation or any other
                acquisition,
                disposal or financing of an organization or a portion of an organization or of any of the business or
                assets
                of an organization.
            </li>
            <li>
                necessary for the detection, investigation, and prevention of fraud, cheating and other violations. This
                data is used only for the purposes of detection, investigation, prevention, and where applicable, action
                on
                such violations, and is stored for the time necessary for this purpose. If such data displays signs of
                violation, we will store such data for the purpose of establishing, exercising or defending legal
                claims,
                where necessary.
            </li>
            <li>any other purposes which we notify you of at the time of obtaining your consent</li>
        </ol>
        <p>
            At any point of time, should you feel the need to opt-out future communications with bittopup, options are
            given within to exclude those communicated messages to you.
        </p>
    </section>
    <section id="section-08">
        <h3>What Legal Bases Do We Rely On To Process Your Information</h3>
        <p><b>If you are located in the EU or UK, this section applies to you</b></p>
        <p>
            The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we
            rely
            on in order to process your personal information. As such, we may rely on the following legal bases to
            process
            your personal information:
        </p>
        <p>
            <b>Consent.</b>
            We may process your information if you have given us permission to use your personal information for a
            specific purpose. You can withdraw your consent at any time.
        </p>
        <p>
            <b>Performance of a Contract.</b>
            We may process your personal information when we believe it is necessary to fulfill our contractual
            obligations to you, including providing our Services or at your request prior to entering into a contract
            with
            you.
        </p>
        <p>
            <b>Legitimate Interests.</b>
            We may process your information when we believe it is reasonably necessary to achieve our legitimate
            business
            interests and those interest do not outweigh your interests and fundamental rights and freedoms. For
            example,
            we may process your personal information for some of the purposes described in order to:
        </p>
        <ol>
            <li>Send users information about special offers and discounts on our products and services</li>
            <li>Develop and display personalized and relevant advertising content for our users</li>
            <li>Analyse how our Services are used so we can improve them to engage and retain users</li>
            <li>Support our marketing activities</li>
            <li>Diagnose problems and/or prevent fraudulent activities</li>
            <li>Understand how our users use our products and services so we can improve user experience</li>
        </ol>
        <p>
            <b>Legal Obligations.</b>
            We may process your information where we believe it is necessary for compliance with our legal obligations,
            such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights,
            or
            disclose your information as evidence in litigation in which we are involved.
        </p>
        <p>
            <b>Vital Interest.</b>
            We may process your information where we believe it is necessary to protect your vital interests or the
            vital
            interests of a third party, such as situations involving potential threats to the safety of any person.
        </p>
        <p><b>If you are located in Canada, this section applies to you</b></p>
        <p>
            We may process your information if you have given us specific permission to use your personal information
            for
            a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at
            any time.
        </p>
        <p>
            In some exceptional cases, we may be legally permitted under applicable law to process your information
            without your consent, for example:
        </p>
        <ol>
            <li>
                If collection is clearly in the interests of an individual and consent cannot be obtained in a timely
                way
            </li>
            <li>For investigations and fraud detection and prevention</li>
            <li>For business transactions provided certain conditions are met</li>
            <li>
                If it is contained in a witness statement and the collection is necessary to assess, process, or settle
                an
                insurance claim
            </li>
            <li>For identifying injured, ill or deceased persons and communicating with next of kin</li>
            <li>
                If we have reasonably grounds to believe an individual has been, is, or may be victim of financial abuse
            </li>
            <li>
                If it is reasonable to expect collection and use with consent would compromise the availability or the
                accuracy of the information and the collection is reasonable for purposes related to investigating a
                breach
                of an agreement or a contravention of the laws of Canada or a province
            </li>
            <li>
                If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
                relating to
                the production of records
            </li>
            <li>
                If it was produced by an individual in the course of their employment, business or profession and the
                collection is consistent with the purposes for which the information was produced
            </li>
            <li>If the collection is solely for journalistic, artistic or literary purposes</li>
            <li>If the information is publicly available and is specified by the regulations</li>
        </ol>
    </section>
    <section id="section-09">
        <h3>How Long We Store Your Data</h3>
        <p>
            We will keep your information for as long as is required to fulfil the purpose for which it has been
            collected
            and processed or if any applicable legislation requires longer storage as required by law.
        </p>
        <p>
            If you terminate your account with us, all personal data will be deleted except if it is required by legal
            process or any other legitimate reason as bittopup deems necessary. If you remove the consent of processing
            personal data of your child, we will delete the personal data without delay based on the consent you have
            given. If you choose to object to the processing of your personal data, we will delete your data within a
            reasonable period, except if it is required by law to retain the same.
        </p>
    </section>
    <section id="section-10">
        <h3>What We Request From You</h3>
        <p>
            We request you to provide us accurate and complete information about yourself and any other person whose
            personal information you provide us and for updating when it becomes incorrect or out of date by contacting
            us.This obligation is a condition to the provision of our Products and/or Services to you and/or any other
            person authorized or permitted by you or your organization/company to use the Products and/or Services.
        </p>
    </section>
    <section id="section-11">
        <h3>We Promise Privacy &amp; Security</h3>
        <p>
            Both of us together play an important role in protecting against online fraud. You should be careful that
            any
            information including your User ID, Password, Security Device and/or Security Code are not compromised by
            ensuring that you do not knowingly or accidentally share, provide or facilitate unauthorized use of it. Do
            not
            share your User ID, Password, Security Device and/or Security Code or allow access or use of it/them by
            others.
        </p>
        <p>
            At bittopup, we use encryption, firewalls and other technology and security procedures to help protect the
            accuracy and security of your personal information and prevent unauthorized access or improper use. For
            example, you will note that while using some features of the bittopup’s website you will need to submit a
            password or some other type of authenticating information.
        </p>
        <p>
            If you click a link to a third-party site, you will be leaving our Platform and we don’t control or endorse
            what is on third-party sites.
        </p>
    </section>
    <section id="section-12">
        <h3>Your Rights</h3>
        <p>
            Individuals located in certain countries, including the European Economic Area and the United Kingdom, have
            certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you
            may have the right to request access to your personal data, as well as to seek to update, delete or correct
            this information.
        </p>
        <p>
            To the extent that the processing of your Personal Data is subject to the General Data Protection Regulation
            (or applicable laws covering the processing of Personal Data in the United Kingdom), bittopup relies on its
            legitimate interests, described above, to process your data. bittopup may also process your personal data
            for
            direct marketing purposes, and you have a right to object to our use of your personal data for this purpose
            at
            any time.
        </p>
    </section>
    <section id="section-13">
        <h3>Disclosure of Your Information (If Needed)</h3>
        <p>
            In addition to the above, when you have provided Personal Information to us for a particular purpose, we may
            share your data with third-party vendors, service providers, contractors or agents (“
            <b>third parties</b>
            ”) who perform services for us or on our behalf and require acces to such information to fulfill your
            request.
            The categories of third parties we may share personal information with are as follows:
        </p>
        <ol>
            <li>Affiliate Marketing Programs</li>
            <li>Cloud Computing Services</li>
            <li>Communication &amp; Collaboration Tools</li>
            <li>Data Analytics Services</li>
            <li>Data Storage Service Providers</li>
            <li>Finance &amp; Accounting Tools</li>
            <li>Order Fulfillment Services Providers</li>
            <li>Payment Processors</li>
            <li>Performance Monitoring Tools</li>
            <li>Social Networks</li>
            <li>Ad Networks</li>
            <li>Testing Tools</li>
            <li>User Account Registration &amp; Authentication Services</li>
            <li>Website Hosting Service Providers</li>
            <li>Products Engineering &amp; Design Tools</li>
            <li>Sales &amp; Marketing Tools</li>
        </ol>
        <p>
            We may also disclose any of your Personal Information to law enforcement or other appropriate third parties
            in
            connection with criminal investigations, investigation of fraud, infringement of intellectual property
            rights,
            or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem
            necessary in our sole discretion, in order to protect the legitimate legal interests of bittopup.
        </p>
        <p>We also may need to share your personal information in the following situations:</p>
        <ol>
            <li>
                <b>Business Transfers.</b>
                We may share or transfer your information in connection with, or during negotiations of, any merger,
                sale of
                company assets, financing or acquisition of all or a portion of our business to another company.
            </li>
            <li>
                <b>Affiliates.</b>
                We may share your information with our affiliates, in which case we will require those affiliates to
                honor
                this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners
                or
                other companies that we control or that are under common control with us.
            </li>
            <li>
                <b>Business Partners.</b>
                We may share your information with our business partners to offer you certain products, services or
                promotions.
            </li>
        </ol>
    </section>
    <section id="section-14">
        <h3>Withdrawing Consent or Requesting Access to Correct Information</h3>
        <p><b>Withdraw Consent</b></p>
        <p>
            To withdraw consent, you may email us at helper@bittopup.com. You may also withdraw your consent by deleting
            your account by choosing the menu items My Account -&gt; Edit -&gt; Delete Account. We will process such
            requests accordingly. You agree that by your withdrawal of consent, you may not be able to continue using
            our
            Services in full or have full access to our Platform and we may terminate the contract you have with us. We
            will liaise with you if we are unable to verify your identity or understand your instructions.
        </p>
        <p><b>Requesting Access and/or Correcting Personal Data</b></p>
        <p>
            If you have an account with us, you may have access to your personal data currently in our possession
            through
            the User Profile page on our Platform. Alternatively, you may submit a written request at
            helper@bittopup.com.
        </p>
        <p>
            When requesting access to personal data, we must have sufficient information from you to deal with the
            request.
        </p>
        <p>
            When requesting to correct personal data, we will correct the same within the stipulated timeline required
            according to the applicable laws, subject always to us being given sufficient information to verify and deal
            with such requests.
        </p>
    </section>
    <section id="section-15">
        <h3>Notices to the Changes in Privacy Policies</h3>
        <p>
            bittopup reserves the right to change this Privacy Policy at any time by notifying registered users via
            e-mail
            of the existence of a new Privacy Policy and/or posting the new Privacy Policy on bittopup. All changes to
            the
            Privacy Policy will be effective when posted, and your continued use of bittopup, product or service after
            the
            posting will constitute your acceptance of, and agreement to be bound by, those changes.
        </p>
        <p>
            We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our
            website through behavioral metrics, heatmaps, and session replay to improve and market our
            products/services.
            Website usage data is captured using first and third-party cookies and other tracking technologies to
            determine the popularity of products/services and online activity. Additionally, we use this information for
            site optimization, fraud/security purposes, and advertising. For more information about how Microsoft
            collects
            and uses your data, visit the
            <a rel="nofollow" href="https://privacy.microsoft.com/privacystatement">Microsoft Privacy Statement</a>
            .
        </p>
    </section>
    <section id="section-16">
        <h3>Contacting BitTopup</h3>
        <p>
            Please feel free to contact us if you have any questions about this Privacy Policy, or if you are seeking to
            exercise any of your statutory rights. We will respond within a reasonable timeframe. You may contact us at
            helper@bittopup.com.
        </p>
    </section>
</article>
<address style="text-align: right">
    <p>This website is owned and operated by</p>
    <p>TOPCOSMOS TECHNOLOGY LIMITED</p>
    <p>UNIT A17, 29/F, LEGEND TOWER, NO.7 SHING YIP STREET, KWUN TONG, KOWLOON, HONG KONG</p>
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